Denver | Fort Collins | Greeley WWW.CP2LAW.COM COAN, PAYTON & PAYNE, LLC PROVIDES A FULL RANGE OF LEGAL SERVICES TO THE BANKING INDUSTRY. R. Clay Bartlett G. Brent Coan Natalie Curry Amanda T. Huston Steven Mulligan Michael C. Payne Brett Payton Julie Trent Matthew L. Chudacoff that can be controlled and expedited by your bank. Have a cyber-forensic firm engaged and on retainer. Make sure you fully understand your insurance coverage and how to quickly invoke it. Engage other vendors, like notice services and call center services, ahead of time to make the notice process more expedient. Hire a PR firm to help get ahead of messaging. Engage in a data mapping exercise to have a full understanding of where all of your consumer personal information is stored and who has access to it. Conduct run-throughs of your cyber incident response plan to ensure that it can be quickly invoked and followed. Finally, with this new theory of damages gaining steam, it may make sense to address it in your customer contracts. Have your customers acknowledge that while the bank is committed to protecting your personal information, and goes to great expense to do so, no information is 100% secure. Data breaches are inevitable, but with a solid prevention program and good documentation on all of the internal and external costs of your program, you will have a much better defense that the ticket was worth the price of admission. Stephen J. Cosentino, CIPP, is a partner at Stinson LLP in the firm's Kansas City office. He may be reached at steve.cosentino@stinson.com. Perry L. Glantz is a partner at Stinson LLP in the firm's Denver office. He may be reached at perry.glantz@stinson.com. To advertise in this magazine, contact us today. 801.676.9722 | 855.747.4003 thenewslinkgroup.org sales@thenewslinkgroup.com It’s your time to grow. July • August 2022 17
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